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6104.63.20 and Section 338 Canada: Rates, Scope, and Stacking

Published: August 13, 2026  ·  7 min read
6104.63.20 and Section 338 Canada: Rates, Scope, and Stacking
Photo: Polina Tankilevitch / Pexels

Key Points

On this page

  1. What HTS 6104.63.20 covers
  2. Base MFN rate and Column 2 rate
  3. Special (FTA) rates and who qualifies
  4. Section 338 Canada overlay: what it is and when it applies
  5. How the duties stack on a live entry
  6. What importers should do
  7. Key references

HTS 6104.63.20 is a Chapter 61 classification for knitted or crocheted women's suits and similar garments described as "Other" under heading 6104. The base MFN duty rate is 28.2%. Canada-origin shipments entered on or after 2026-08-19 carry an additional Section 338 tariff overlay declared under Chapter 99 codes 9903.03.12 through 9903.03.16. The links in this article go to the primary documents: the official tariff schedule, Federal Register notices, White House proclamations, and CBP guidance pages themselves. Read the source.

What HTS 6104.63.20 covers

Heading 6104 covers women's suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches, and shorts that are knitted or crocheted. Subheading 6104.63 narrows the scope to garments of synthetic fibers, and the 8-digit breakout 6104.63.20 captures the residual "Other" category within that subheading.

Because this is a Chapter 1-97 classification, it is the code that drives the base duty rate and any applicable FTA treatment. When a Chapter 99 overlay applies, such as Section 338, the Chapter 99 code rides on a separate line of the entry summary alongside the 6104.63.20 line. Confirm the exact product scope by reviewing the current schedule at hts.usitc.gov.

Base MFN rate and Column 2 rate

Column 1 (MFN) rate: 28.2%

The General (Column 1) rate for 6104.63.20 is 28.2% ad valorem, as of August 10, 2026. This rate applies to goods originating in any country that holds normal trade relations (MFN) status with the United States and that do not qualify for a preferential FTA rate. The 28.2% is assessed on the customs value of the imported goods, which in most transactions is the transaction value. For a practical overview of how that value is determined, see our article on Customs Transaction Value: The Default Valuation Method Explained.

Column 2 rate: 72%

For countries not entitled to MFN treatment, the Column 2 rate is 72% ad valorem. This rate is rarely encountered in practice but should be confirmed for any origin that does not hold normal trade relations status with the United States.

Special (FTA) rates and who qualifies

The Special rate column for 6104.63.20 provides a free (0%) duty rate for goods originating in the following countries or trade agreement beneficiaries, as shown in the HTSUS schedule as of August 10, 2026:

Canada is not on this list. Canadian-origin goods do not receive the 0% Special rate for this subheading. Instead, they are subject to the MFN rate of 28.2% plus, for entries on or after 2026-08-19, the Section 338 overlay described below.

To claim a Special rate, the importer must have a valid certificate or other proof of origin, the goods must meet the applicable rules of origin, and the correct claim must appear on the entry summary. If the facts of a specific transaction are unclear, confirm with your broker before filing.

Section 338 Canada overlay: what it is and when it applies

What Section 338 is

Section 338 is a tariff action targeting Canada-origin goods. It is implemented through Chapter 99 of the HTSUS. The operative Chapter 99 codes for Section 338 are 9903.03.12 through 9903.03.16. These codes are distinct from the now-defunct Section 122 block (9903.03.01 through 9903.03.11), which is no longer in effect. Do not confuse the two ranges on entry preparation.

Effective date and scope

The Section 338 overlay applies to entries of Canada-origin goods classified under 6104.63.20 that are filed on or after 2026-08-19. Shipments entered before that date are not subject to the overlay under this program. Confirm the applicable rate for the Section 338 Chapter 99 codes by checking the current HTSUS at hts.usitc.gov, as the facts block is silent on the specific ad valorem increment imposed by 9903.03.12 through 9903.03.16 for this commodity.

For context on how Section 338 applies across other product categories, see our articles on 6104.43.20 and Section 338 Canada and 6110.20.20 and Section 338 Canada.

How the duties stack on a live entry

When a Canada-origin shipment of goods classified under 6104.63.20 enters the United States on or after 2026-08-19, the entry summary will carry two tariff lines:

Both lines are assessed on the same customs value. The total duty burden is the sum of both rates. This stacking structure is standard for Chapter 99 overlays: the Chapter 1-97 line drives classification and the base rate, while the Chapter 99 line adds the overlay. CBP will reject entries that omit a required Chapter 99 code, so coordinate with your broker to ensure both lines appear correctly on the entry summary.

For goods originating in FTA countries listed above, the base duty collapses to 0%, but those countries are not subject to Section 338, so the Chapter 99 line would not apply. Canada-origin goods receive no FTA relief under this subheading and are subject to both layers.

Use our duty calculator to model the combined duty bill for a specific shipment value. For an overview of other 2026 tariff code changes, see our 2026 tariff code overview.

What importers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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